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Reduce Repetition: Four Ways to Break the ‘We’ve Heard This’ Reaction

Yesterday was an historic day in the U.S. House of Representatives. For more than eight hours, Democratic and Republican members of the body gave short alternating speeches for and against the motion, before impeaching Donald...more

Use Physical Exhibits: Be 3-D

Once, while I was monitoring a science-intensive agricultural contamination case, we asked permission for one of our expert witnesses to have the jurors peer into a dark box where they could see a petri dish with a bacteria...more

Expect that Jurors Might Generate Their Own Fake News

Every day, we are reminded that we live in a new age that can be called “post-truth.” We pay a lot of attention to external sources of misinformation, whether it is motivated public figures, partisan news networks or...more

Don’t Ask Your Audience to Follow Substructure: Five Reasons Flat Structure Is Better

There is one habit of attorneys that promotes precision in analytical thinking, but often interferes with the ability to clearly communicate with the audience. That habit is the tendency to divide points into sub-points, and...more

Account for the ‘Ethics Tax’ on Female Leaders

The arc of history has been moving, albeit in fits and starts, toward gender equality. In the business world, and a little less in the legal world, we see more female leaders at the top. But once a woman reaches that point,...more

Adapt to Evolving Attention

You’ve probably seen the claim, but is it really true that our attention spans are becoming shorter than that of a goldfish? Last year, the presentation software company called Prezi released its 2018 State of Attention...more

Thank Your Jurors…Just Don’t Go Overboard

I remember once sitting in court early into the defense opening statement, and the attorney was busy thanking the jurors, again. Even though they had already heard the spiel from the other side, and from this attorney’s...more

Let the Judges Judge (and Not Settle Cases)

You’re heading to trial and there is one last hurdle: the mandatory settlement conference that your judge is gunning for. He has signaled at every opportunity that he thinks this is a case the parties should resolve prior to...more

Be “Tough and Firm” Rather than “Warm and Friendly” in Negotiations

There’s an old expression: “You can catch more flies with honey than with vinegar.” Assuming that your goal is not to actually catch flies, but instead, to get what you want in some kind of negotiation, the expression means...more

Whistleblowers, Remember Credibility is Still Part of the Story

What started with an anonymous whistleblower report regarding President Trump’s pressure on the government of Ukraine to investigate his political opponents has blossomed into a parade of witnesses testifying in a soon-to-be...more

Think About Your Case Like an Investor

I spoke with some defense attorneys recently who were surprised to learn of existence of third- party litigation funding groups. These financial companies who will front cash for litigation and trial expenses in hopes of...more

Fight Your Stage Fright by Reframing

Since it’s Halloween, let’s consider a frightful topic. Experienced trial lawyers usually get past their stage fright early on, and even come to relish the idea of standing in front of a jury, or most any audience. But...more

Look Out for the Illusory Truth Effect

There’s a cartoon that shows a the philosopher, Plato, sitting on the grass of Athens with a modern-day politician (variously, it is Karl Rove or Donald Trump), with the latter character saying to Plato, “But surely you agree...more

Defendants, Include a “Here’s What You Haven’t Heard” in Your Opening Statement Introduction

The law allows counsel on the other side to deliver their opening statement first, so they get the early opportunity to tell you their story. But, there are two sides to every story. And, despite all you have heard, I...more

Examining Attorneys, Keep Your Cool

So you’re conducting the cross-examination, and the witness is fighting like a three hundred pound marlin at the end of your fishing line. And they’re not fighting by legitimately drawing distinctions or by using their own...more

Expect that Our Romance with Tech Companies Might Be Over

On a recent series of flights, I watched “Valley of the Boom,” an unconventional but highly- entertaining miniseries focusing on all of the shenanigans that accompanied the early 1990’s Silicon Valley technology boom and...more

For Immediacy, Use Active Voice (but for Abstraction, Passive Voice Can Be Used)

You probably learned it in one of your earliest writing classes: Active voice means the grammatical subject is doing the acting, and passive voice means the subject is acted upon. It is the difference between “The dog bit the...more

Address the ‘My House, My Responsibility’ Analogy

There is a persistent belief among many mock jurors that I have seen in certain kinds of cases. The belief is that liability attaches automatically to possession, and jurors usually express it through the lens of home...more

Train Your Witness to Combat Simplistic Equivalence

God is Love - Love is Blind - Stevie Wonder is Blind -Therefore, Stevie Wonder is God - That’s an exaggerated version of a kind of fallacious thinking that is often used in witness examination. It is a form of the...more

Appreciate the Nuance of a Theme

When you are working on boiling down your message, there will often be that indefinable “something” that makes you recognize when you have the right language. A good trial theme, for example, doesn’t just summarize the...more

Understand Jurors’ Process on Pain and Suffering

Juror 1: “The next category is ‘pain and suffering.’ How are we supposed to get to get that number?” Juror 2: “It is just whatever we want…there’s no guidance for it.“ Juror 1: “How are we supposed to do that? Put a...more

Address the Central Unknown

Congress and the American public have been gripped by some unknowns recently. A whistleblower in the intelligence community made a claim that the Inspector General considered both credible and urgent. But, initially at least,...more

Treat Trust as a Layered Thing

The government often plays a background role in civil litigation. An action, decision, or product from one party might meet the government’s regulations, for example. The question that raises is “Are the regulators trusted?”...more

Speak to the Personal Responsibility Divide

On one end of the spectrum, there are specific beliefs jurors might hold on an issue. More generally, then there are attitudes that cover and predict many of those different beliefs. Even more generally, there is the...more

Take It Seriously: Potential Jurors Cannot Self-Diagnose Their Bias

As I’ve written before, it is never safe to trust a potential juror’s own opinion about whether they are biased or not. That is because there has never been much support in the social science for that ability to...more

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